I want to say immediately I am not asking which one is correct, because I am sure every Sensei has his own method to teach.
When Sensei taught me Yokomenuchi he placed a bokken in front of him and he told me to hit him with a Shomenuchi. From there I learnt that according to the distance either I slide in with a very little angle and then step drawing my line through Nage and deliver the Shomenuchi or if closer I just step with a little side angle drawing my line through Nage and deliver the Shomenuchi (meaning in both cases strike starting from top of my head).
I have seen in many videos that some people deliver a Yokomenuchi stepping streight into Nage delivering a strike starting from the side of Uke's head and landing to the side of Nage's head.
Now my question. In both cases the final destination of the strike remains the side of the Hgae's head, but the position of Uke's body is very different. Will this deeply effect the technique to apply?
(Sorry if a beginner's question, but that's what I am hee hee).
Let's get back to basics.
YOKO - Side
MEN - Head
UCHI - Strike/Hit
Therefore YOKO-MEN-UCHI is hitting the head sideways.
Whether your body move to an angle or not to hit... both are still YOKO-MEN-UCHI. Aim is to hit side of head.
To answer your question, final position of tori relative to uke will depend on whether if there are any pointy metallic or wooden object hindering your way or not. Either way, both are still YOKO-MEN-UCHI.